The most common categories of SEBI investigation GP defends are: insider trading under the SEBI (Prohibition of Insider Trading) Regulations 2015 — trading by a connected person on the basis of Unpublished Price Sensitive Information (UPSI); market manipulation and fraudulent trade practices under the SEBI (PFUTP) Regulations 2003, including front-running, circular trading, and spoofing; and AIF, PMS, and broker regulatory violations including KYC failures and mis-selling.
GP's SEBI practice covers the investigation phase (summons response, document production, statement preparation) and the adjudication phase (SCN reply, Whole Time Member hearing, SAT appeal). For clients seeking to avoid contested adjudication, GP manages the consent mechanism — allowing settlement by payment without a formal guilt finding.
Advisory from the first SEBI contact — summons under Section 11C, document requests, or inspection notices. GP advises on the response obligation, legal representation rights at the Section 11C examination, the documents that must be produced versus those that are privileged, and the statement preparation process. The first response to SEBI defines the entire investigation — a well-prepared statement significantly reduces the risk of an adverse adjudication.
Preparation of the SCN reply — the most important document in the adjudication process. GP analyses SEBI's prima facie findings against the record, identifies factual and legal flaws in SEBI's analysis, and prepares a comprehensive reply before the Whole Time Member. The SCN reply is the foundation of the adjudication defence — a poorly prepared reply limits arguments available at the hearing and on appeal.
Defence of insider trading allegations — challenging whether the alleged information meets the UPSI definition, whether the connected person had access to the UPSI, whether the trading pattern is consistent with the allegation, and whether statutory defences (trading plan, off-market transfer) are available. Insider trading defences require integrated legal expertise and quantitative trading data analysis.
Defence of PFUTP allegations — front-running, circular trading, pump-and-dump, spoofing — under the SEBI (PFUTP) Regulations 2003. GP challenges SEBI's market analysis methodology, the attribution of trades to the respondent, and the characterisation of legitimate strategies as manipulative. PFUTP defences require detailed trading data analysis and surveillance methodology review.
Management of the consent mechanism application — SEBI's framework for settling matters without a formal adjudication finding. GP negotiates consent terms with SEBI's High Powered Advisory Committee, prepares the consent application, and manages the approval. Consent is most effective where SEBI's findings are likely to be upheld and the consent fee is proportionate to the likely adjudication penalty.
Filing and conduct of appeals before the Securities Appellate Tribunal against SEBI adjudication orders — debarment, disgorgement, monetary penalties. GP files urgent stay applications where SEBI's order has immediate market consequences (debarment from trading, suspension of registration) and conducts the full merits appeal before SAT.
The PIT Regulations define UPSI broadly — information relating to the company that is not generally available and likely to materially affect prices. Many insider trading cases turn on whether the information was "generally available" (not UPSI) or whether it would "materially affect" prices (requiring quantitative evidence). GP challenges SEBI's UPSI characterisation where the information is arguably public or has limited price impact.
The PIT Regulations create a rebuttable presumption that certain persons — immediate relatives, specified associates — are deemed to have UPSI access. The presumption is rebuttable through communication records, physical separation, and different trading patterns. GP builds the rebuttal evidence to establish that the deemed connected person had no actual UPSI access.
A consent order explicitly states that it is made without any admission or denial of guilt. For respondents wishing to resolve matters without a formal finding, consent is often optimal — provided the consent fee is proportionate to the likely adjudication penalty. GP assesses the consent vs. contest decision at the outset of every SEBI matter.
GP's SEBI practice covers the entire lifecycle — from first summons through Section 11C examination, SCN preparation, Whole Time Member hearing, SAT appeal, and High Court challenge. Understanding how each stage affects the next is the core of effective SEBI defence.
SEBI matters require legal analysis integrated with quantitative analysis of trading data. GP works with forensic financial analysts who challenge SEBI's trading analysis, market impact calculations, and disgorgement methodology — providing the technical counterpoint to SEBI's surveillance-based findings.
GP advises clients on the realistic probability of success at each stage and the cost, time, and reputational consequences of a full contest versus consent. Where evidence is strong, GP fights. Where a negotiated outcome is in the client's interest, GP manages the consent process efficiently.
Defended a Mumbai listed company promoter who received a SEBI debarment order for alleged insider trading. GP filed a SAT appeal within seven days, securing a stay of the debarment. GP challenged the UPSI characterisation — the acquisition target's identity had been reported in a business newspaper six weeks before the trading, making it "generally available." GP also rebutted the connected person presumption through communication records showing no contact during the alleged UPSI period. SAT set aside the debarment and disgorgement on both grounds.
Managed a consent settlement for a Delhi broker facing a PFUTP front-running allegation. GP reviewed the trading data with a forensic analyst, assessed the realistic merits, and advised that consent was in the client's interest. GP negotiated a consent fee of Rs.85 lakh and a six-month voluntary certificate surrender — significantly less than the likely adjudication penalty of Rs.4-6 crore and permanent debarment.
Filed a writ petition for an AIF manager whose registration was cancelled by SEBI following an investigation. GP challenged the cancellation on natural justice grounds — SEBI had not provided the investigation report before cancelling registration. The Bombay HC stayed the cancellation and remanded the matter to SEBI for reconsideration with proper procedure.
The SEBI practice integrates legal process expertise with forensic financial analysis — covering the full lifecycle from initial summons through SAT and High Court proceedings.
For clients in concurrent SEBI and PMLA proceedings — common in insider trading and market manipulation matters — GP's anti-money laundering practice provides integrated dual-regulator defence.
The Section 11C examination, the document production obligation, and the five most damaging mistakes respondents make in the first week of a SEBI investigation.
Read Insight →The contested boundary of the UPSI definition, the generally available test, and the quantitative analysis that supports a strong insider trading defence.
Read Insight →Whether you need pre-investigation advice, are responding to a regulator notice, or are defending enforcement action — speak to GP today.